Chapter 8: Miniature Golf Courses

8.1 Number of Facilities

Existing Facilities

The 1997 Economic Census counted 1,041 miniature golf courses operated by private entities.63 This number does not include facilities such as family entertainment centers, amusement parks, motels, hotels, resorts, and recreational vehicle parks and camps that operate miniature golf courses, but the activity does not account for the major portion of the facility’s receipts. Public parks and recreation districts may also operate miniature golf courses. The Miniature Golf Association United States (MGAUS) estimated there are 7,500 to 10,000 existing miniature golf courses, including custom design and modular courses.64

New Construction

The MGAUS estimated 550 new custom design and 850 new modular miniature golf courses would be constructed over the next five years. Based on the MGAUS estimate and interviews with companies that make miniature golf courses, we estimated that 150 new custom design and 170 new modular miniature golf courses would be constructed each year.

Small Entities

For miniature golf courses operated by private entities, using the methodology described in Chapter 2, we estimated 100 percent are small entities. For miniature golf courses operated by public entities, we assumed the percentage operated by small governmental jurisdictions is the same as in Table 2.1.

8.2 Final Guidelines

Table 8.1 summarizes the final guidelines for miniature golf courses.

Table 8.1 - Final Guidelines: Miniature Golf

Section

Requirement

15.5.1 General

Application

Newly designed and constructed and altered miniature golf courses must comply with 15.5.

15.5.2 Accessible Holes

Scoping

Exception - Consecutive Accessible Holes

At least 50% of holes must be accessible. Accessible holes must be consecutive.

One break in sequence of consecutive accessible holes permitted, provided last hole on course is last hole in sequence.

15.5.3 Accessible Route

General

Exceptions - Accessible Route Located on Playing Surface

Accessible Route Adjacent to Playing Surface

Accessible route must connect course entrance and start of play area of each accessible hole. Course must be configured to allow exit from last accessible hole to course entrance/exit without traveling back through holes.

Where accessible route located on playing surface, carpet and handrail requirements do not apply; 1 inch maximum curb permitted for 32 inches minimum width to contain ball; 1:4 maximum slope permitted for 4 inch maximum rise; landings required by 4.8.4 permitted to be 48 inches minimum in length; landings required by 4.8.4(3) permitted to be 48 inches by 60 inches minimum; and landing slopes permitted to be 1:20 maximum.

Where accessible route located adjacent to playing surface, accessible route requirements apply.

15.5.4 Start of Play Areas

General

Start of play areas at accessible holes must be 48 inches by 60 inches minimum and have slopes not steeper than 1:48.

15.5.5 Golf Club Reach Range

General

All areas within accessible holes where golf balls rest must be within 36 inches maximum of accessible route having maximum slope of 1:20 for 48 inch length.

8.3 Alternatives

Table 8.2 presents the alternatives considered in the proposed guidelines and final guidelines. The significant comments raised during the public comment period are summarized in the preamble to the final rule, along with the Access Board’s assessment of the comments and the reasons for selecting the alternative adopted in the final guidelines. The Access Board minimized the significant economic impact of the final guidelines by requiring at least 50 percent of holes on miniature golf courses to be accessible, and permitting one break in the sequence of accessible holes, provided the last hole on the course is the last hole in the sequence. The final guidelines also allow designers and operators greater flexibility in applying the accessible route requirements in ADAAG to new and altered miniature golf courses.65

Table 8.2 - Miniature Golf Alternatives

Item

Proposed Guidelines

Final Guidelines

Accessible Holes - Scoping

Each hole must be accessible. Exception permits at least 50% of elevated holes to be accessible.

At least 50% of holes must be accessible. Accessible holes must be consecutive. Exception permits one break in sequence of consecutive accessible holes, provided last hole on course is last hole in sequence.

Where accessible route located on playing surface, handrail requirements do not apply and 1:4 maximum slope permitted for 4 inch maximum rise.

Where accessible route located on playing surface, carpet and handrail requirements do not apply; 1:4 maximum slope permitted for 4 inch maximum rise; landings required by 4.8.4 permitted to be 48 inches minimum in length; landings required by 4.8.4(3) permitted to be 48 inches by 60 inches minimum; and landing slopes permitted to be 1:20 maximum.

Start of Play Areas

Start of play areas at accessible holes must be 60 inches by 60 inches minimum and have slopes not steeper than 1:48.

Start of play areas at accessible holes must be 48 inches by 60 inches minimum and have slopes not steeper than 1:48.

Golf Club Reach Range

Level areas within accessible holes where golf balls rest must be within 27 inches maximum of accessible route with 1:20 maximum slope.

All areas within accessible holes where golf balls rest must be within 36 inches maximum of accessible route having maximum slope of 1:20 for 48 inch length.

8.4 New Construction Impacts

To better understand the new construction impacts, we interviewed several companies that make custom design and modular miniature golf courses.66 These courses are constructed outdoors and indoors.

Custom Design Courses

Although each company considered its designs to be unique, custom design miniature golf courses can generally be divided into three types: low profile courses, challenge courses, and adventure style courses. We examined the potential impacts of the final guidelines in terms of size of the course and additional construction costs.

Low Profile Courses - Low profile courses present the fewest issues in terms of potential impacts. These courses are constructed in the ground and follow the contour of the existing land which is usually flat. These courses typically range in size from 12,000 to 20,000 square feet. The start of play areas is usually 5 feet wide. Some holes may be designed for skilled bank shots off the edge system. Other holes may have obstacles and themeing to provide a unique experience. We assumed an accessible route can be provided through at least 50 percent of the holes and the impacts on low profile courses would be minimal. We assumed 20 percent of new custom design miniature golf courses (30 new facilities per year) would be low profile courses.

Challenge Courses - Challenge courses are constructed with contour changes to make the game challenging and interesting to play, and to produce frequent repeat play. Streams, waterfalls, rock gardens, caves, planters, and other landscaping effects may be incorporated into the design to separate the holes and give the course a more interesting overall experience. The holes may have elevation changes up to 2 feet or more. Some challenge courses may also incorporate elements of the adventure style design, and construct mountains with elevation changes of 20 feet or more. In these courses, some holes may be designed around the base of the mountain, and other holes may be designed into the mountain. Challenge courses typically range in size from 22,000 to 32,000 square feet, and the holes range in size from 175 to 300 square feet. The start of play areas are usually 5 feet wide, and the holes may be up to 40 feet long. The cost to construct a challenge course ranges from $200,000 to $300,000 or more. We used a midpoint of $250,000 in this assessment. We assumed 70 percent of new custom design courses (105 new facilities per year) would be challenge courses. The additional costs incurred as a result of the final guidelines will vary depending on the specific design. Most of the companies we interviewed said they were using the draft final guidelines to design new courses to be accessible. Some companies said they have been designing accessible courses for years. One company, which constructs about 40 challenge courses per year, said the final guidelines would have minimal impact on the new courses it constructs. Another company said it incorporated the draft final guidelines in its computer aided design (CAD) program and the impacts are minimal. Other companies that have used the draft final guidelines said accessible courses cost 10 percent to 15 percent more to construct. These additional costs were for building ramps and retaining walls into the side of hills to provide accessible routes. For purposes of this assessment, we assumed the final guidelines would add 10 percent to the construction costs for challenge courses. The total annual compliance costs for challenge courses are $2.6 million.

Adventure Style Courses - Adventure style courses are constructed by adding fill to create mountains with elevations up to 40 feet or more. Some courses are built on the sides of mountains, hills, ravines, and highway embankments and use the existing topography. Streams, waterfalls, rock gardens, caves, planters, and other landscaping effects are usually incorporated into the design. Adventure style courses are typically constructed at tourist destinations and are designed to present a dramatic presentation to attract customers. On the high end, a 36 hole adventure style course can be 3 acres or more, and costs $1.0 million or more to construct.67 The holes on the high end courses are typically11 feet wide and may be up to 80 feet long, with a typical hole being 500 square feet. We assumed 10 percent of new custom design courses (15 new facilities per year) are adventure style courses. The additional costs incurred as a result of the final guidelines will vary depending on the specific design. One company that designs high end adventure style courses said it would have difficulty maintaining its high elevations and dramatic presentations to the road, and would have to compromise its designs by providing some accessible holes at the base of the mountain. If accessible holes are built into the sides of a mountain, it will require extensive ramping and retaining walls, and the construction costs would increase by 20 percent to 40 percent. For purposes of this assessment, we assumed an 18 hole adventure style course costs $500,000, and the final guidelines would add 25 percent to the construction costs. The total annual compliance costs for adventure courses are $1.9 million.

The final guidelines generally would not require an increase in the size of the course, except possibly for the high end adventure style courses that design accessible holes into the side of a mountain and need additional space for ramps. However, the companies stated that the final guidelines would have an impact on the selection of sites. Land that is low priced like landfills, mountains, and irregular sites may be more expensive to develop. Some developers may decide not to build miniature golf courses on such sites, or may decide to acquire more expensive sites that are less expensive to develop.

Modular Courses

Modular courses are pre-engineered and manufactured off site, and then installed at a site. The courses may be permanently installed, or temporarily installed. The impacts will vary depending on whether the course is installed indoors or outdoors.

Indoor Courses - Indoor modular courses may be installed at shopping malls, hotels and resorts, and other facilities with large interior spaces. A nine hole course in an indoor mall typically uses 1,500 to 2,000 square feet. The holes are usually raised 4 inches to 6 inches above the floor, and may be narrow. Providing an accessible route around at least 50 percent of the holes may require additional spacing between the holes, and an increase in the square footage of the course. The additional cost of leasing space may make some indoor courses not economically viable.

Outdoor Courses - Outdoor modular courses may be installed by miniature golf course owners or operators as an economical alternative to custom design courses. Outdoor modular courses may also be installed as an amenity at hotels, and recreational vehicle parks and camps. Outdoor modular courses that are used as an alternative by miniature golf course owners or operators to custom design courses, are installed in the ground. These courses may have contour changes to make the game interesting and challenging. These courses tend to be smaller than custom design courses, and may provide an accessible route through the hole or around the hole. Outdoor modular courses that are used by hotels, and recreational vehicle parks and camps as an amenity may be installed 4 inches to 6 inches above the ground. A nine hole course at a recreational vehicle park typically uses 2,500 square feet. Companies that manufacture modular courses usually recommend that a walkway be provided around the holes. However, the cost of providing a walkway around the holes may not be economically viable for some entities. For example, the cost for a low end nine hole modular course ranges from $6,000 to $8,000; and the cost for a walkway to at least five of the holes ranges from $3,000 to $5,000.

For purposes of this assessment, we assumed the final guidelines will add $5,000 to the cost of new modular courses for providing accessible routes around at least 50 percent of the holes. The total annual compliance costs for new modular courses are $0.9 million.

Revenues and Profitability

The MGAUS has expressed concern that the real financial impact of the final guidelines is not the initial construction costs, but the long term effect on revenues and profitability. The MGAUS believes that making new miniature golf courses accessible would “adversely affect the quality and recreational entertainment of the miniature golf experience in an increasingly competitive market place (i.e., reducing the miniature golf experience to the lowest common denominator, instead of offering the high quality and value experience for all players regardless of ability or disability . . .”). The Access Board has recognized the industry’s concerns and has modified the final guidelines to require at least 50 percent of the holes on new miniature golf courses to be accessible. In the absence of the final guidelines, enforcement action by the Department of Justice or litigation could result in 100 percent of holes being accessible. Many of the companies that custom design miniature golf courses said they are using the draft final guidelines to design new courses. Some companies said they have been designing accessible courses for several years. None of the companies presented information that an accessible course they designed was unprofitable. Most of the companies said they can design a course that provides high quality recreational entertainment and complies with the final guidelines. The only company that expressed reservations about the guidelines compromising designs builds high end adventure style courses.

8.5 Alterations Impacts

The alterations impacts are minimal. Miniature golf courses typically do not replace or reconstruct holes unless the holes are unplayable because of problems such as the ball failing to roll true, or the ball being too easily hit outside the hole into landscape and waterscape areas. Most of the alterations involve changes to landscaping, themeing, hole carpeting, and hole edging. These types of alterations would not generally trigger accessible route requirements.

8.6 Total Costs

For miniature golf courses, the total annual compliance costs are $5.4 million.